Columbia River Basin Tributary Habitat Restoration - Draft Environmental Assessment
The following comments were submitted in response to the open comment period described below.
Comments are numbered consecutively as they are received. Breaks in the number sequence result when comments are deleted because they
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The Bonneville Power Administration in cooperation with the Bureau of Reclamation prepared a draft environmental assessment (EA) for the proposed Columbia River Basin Tributary Habitat Restoration program. The EA describes the program and why it is needed, discusses the environmental impacts the associated projects would create, and lists the mitigation measures that would lessen those impacts.
PROJECT DESCRIPTION:
BPA in cooperation with the BOR proposes to implement a programmatic environmental review for tributary fish and wildlife habitat restoration actions throughout the Columbia River Basin in the states of Oregon, Washington, Idaho, Montana, Nevada, and Utah. These actions range from those such as fencing and planting; to bridge construction, instream habitat improvements, and stream channel reconstruction. Together, these actions represent an overall tributary habitat restoration program funded by Bonneville to mitigate for effects of the development and operation of the Federal Columbia River Power System (FCRPS) on fish and wildlife.
For More Information:
https://www.bpa.gov/efw/Analysis/NEPADocuments/Pages/Columbia-River-Basin-Tributary-Habitat-Restoration.aspx
Close of comment: 10/16/2020
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Fee/Washington State Noxious Weed Control BoardNoxious weeds are highly invasive and destructive non-native plants that outcompete native vegetation. Noxious weeds can negatively impact fish bearing waterways, ecosystems, and habitat. Making prevention and control of noxious weeds a high priority protects these areas and lessens the future economic impact of noxious weed infestations.
Section 2.1.3 Category 3 - Invasive Plant Control and Vegetation Management, should include noxious weed species priorities and how local noxious weed regulations will be met.
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moura/Confederated Tribes of the Colville ReservationAttachment received via email. A website glitch is preventing it from being uploaded through the online forum.
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Blank/Washington Department of Fish & WildlifeDear Mr. Shull and Mr. Hamel,
On behalf of the Washington Department of Fish and Wildlife (WDFW), thank you for the opportunity to comment on the National Environmental Policy Act draft environmental assessment (EA) for the Bonneville Power Administration’s Columbia River Basin Tributary Habitat Restoration programmatic environmental review. As WDFW stated in its scoping comments, the tributary habitat work funded by BPA through the Northwest Power and Conservation Council’s (NPCC) Fish and Wildlife Program is critical to meeting these agencies’ fish and wildlife obligations under the Northwest Power Act. Equally importantly, the work is vital to protecting and restoring fish and wildlife around the Columbia Basin, including Washington’s portion of the basin. I hope these brief comments are helpful in informing your approach to this programmatic NEPA review.
WDFW appreciates that the EA acknowledges that the BPA fund projects in close consultation with the NPCC, adhering closely to its Fish and Wildlife Program and with advice from the NPCC’s Independent Science Advisory Board and Independent Science Review Panel, as well as from state and tribal comanagers. Coordinating with the NPCC will ensure an appropriate exploration of alternatives to achieve a positive response in salmon and steelhead life cycle survival and/or abundance. BPA tributary restoration should also take advantage of NPCC and co-manager expertise and guidance, which is also required by the Northwest Power Act.
WDFW continues to encourage the NEPA review to adhere to guiding principles for tributary habitat restoration, emphasizing science-based restoration with rigorous effectiveness monitoring. This is important to the recovery and protection of fish and wildlife, and is also necessary to demonstrate
the value of habitat restoration as mitigation for the hydropower system. As stated in WDFW’s scoping comments, some high priority restoration actions, such as tree planting and floodplain connectivity, take years to provide their intended benefits, while others, such as barrier removals and improving juvenile salmonid survival at irrigation diversions, can provide immediate impact. In general, WDFW supports investing in the highest impact actions even if they take years to realize their full benefits in survival and/or abundance. However, it is helpful to understand which actions have nearer-term benefit. Actions with near-term benefit can be implemented quickly when adaptive management is needed to meet, for instance, needs under the Columbia River System Biological Opinion’s (CRS BiOp) Adaptive Management provisions or emergency actions (presumably as a supplement to additional hydropower system actions). While these concepts are addressed in the EA at a programmatic level, WDFW encourages BPA to collaborate with the NPCC to identify specific mitigation projects, focusing on high-impact, near-term benefit.
WDFW also would like to see a more detailed outline of how this NEPA process will be used to inform mitigation through BPA’s Endangered Species Act consultations with NOAA Fisheries and the U.S. Fish and Wildlife Service. For instance, the mitigation and adaptive management strategies of the new CRS BiOps for salmon, steelhead, and bull trout should be integrated into the results of this review.
The draft EA does not adequately address WDFW’s general recommendation that BPA’s limited resources should focus on recovery of imperiled stocks and on protecting and perpetuating strongholds. WDFW also encourages investment in the recovery of stocks that may be on the brink of Endangered Species Act de-listing.
To restate WDFW’s comments during scoping on the types of tributary habitat protection and restoration, WDFW continues to encourage BPA to consider the following additional action items that could be addressed more directly in the EA:
• Additional actions to improve instream flow, beyond water right acquisitions;
• Actions to specifically reduce high water temperatures in the short-term, including negotiating the cold-water release from tributary dams;
• Work with state fish and wildlife agencies and tribes on strategies to reduce unnatural levels of predation in tributaries (to the extent that tributary predation is covered in this category of Fish and Wildlife Program work).
WDFW continues to support rigorous monitoring and evaluation to understand the benefits of restoration across the salmon life cycle, and the interaction of tributary habitat restoration with mainstem dam operations, including the effects of delayed or latent mortality from hydrosystem passage. We recognize that it is cost prohibitive to monitor life cycle survival or abundance for all individual habitat restoration projects in the Columbia Basin, but we support monitoring life cycle survival and abundance changes in locations where consistent large restoration projects occur, such as the Upper Columbia and Tucannon Habitat Programmatic project areas. The draft EA does not adequately outline how BPA will work with the NPCC Fish and Wildlife Program and co-managers to improve our joint understanding of the efficacy of restoration actions and their interaction with hydropower impacts.
Thank you for your consideration of these comments.
Sincerely,
Ben Blank, Energy Section Manager
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Magdangal/US EPAAttachment received via email.
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Hauser/Upper Snake River Tribes FoundationPlease find attached the comments of the Upper Snake River Tribes Foundation.
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Desautel/Confederated Tribes of the Colville ReservationPlease see the attached.
View Attachment
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Quaempts/Confederated Tribes of the Umatilla Indian Reservation Department of Natural ResourcesPlease find attached the comments of the Confederated Tribes of the Umatilla Indian Reservation Department of Natural Resources on the Columbia River Basin Tributary Habitat Restoration - Draft Environmental Assessment.
View Attachment
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